Britain v. Texas

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A jury convicted appellant Samantha Britain of manslaughter and injury to a child for recklessly causing the death of her step-daughter. The Court of Appeals held that there was insufficient evidence that appellant was "aware of but consciously disregard[ed] a substantial and unjustifiable risk" as required to prove recklessness. Accordingly, the court reversed the trial court and entered a judgment of acquittal on both counts. The Supreme Court granted the State's petition for review of whether the Court of Appeals should have reformed the verdict to the lesser-included offense of criminally negligent homicide rather than rendering a verdict of acquittal. The Supreme Court concluded there was no evidence concerning the standard of care an ordinary person should be held to or that showed the appellant should have been aware of the risk to the child. Given this lack of evidence and the conflicting testimony of the medical experts concerning the ease with which such a serious risk was identified, the Court could not say that the State proved beyond a reasonable doubt that the appellant acted with negligence. The Court of Appeals did not err in rendering a judgment of acquittal, and the Supreme Court affirmed that decision. View "Britain v. Texas" on Justia Law